Response to consultation on Implementing Technical Standards on public disclosures by institutions of the information on operational risk
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Question 1: Are the amended/new templates EU ORA, EU OR1, EU OR2 and EU OR3 and the related instructions clear to the respondents? If no, please motivate your response.
We need clarification on whether the new operational risk disclosure templates apply only to the consolidated Group level or also require individual data reporting. Additionally, we seek clarity on whether these templates should be submitted simultaneously with the solvency templates (C16) or at a later date.
Question 2: Do the respondents identify any discrepancies between these templates and related instructions and the calculation of the requirements set out in the underlying regulation?
No.
Question 3: Do the respondents agree that the amended draft ITS fits the purpose of the underlying regulation?
Yes.
Question 4: Do the respondents consider that the “mapping tool” appropriately reflects the mapping of the quantitative disclosure templates with supervisory reporting templates?
Yes.